However, it is only since 2014 that HMRC has been able to issue Advanced Payment Notices to expatriates who have used disputed tax avoidance / tax minimisation schemes. These APNs mean that those under investigation must pay upfront and dispute later.
There are a number of issues to consider for expatriates under investigation, not least for high net worth individuals living abroad who may find themselves unfairly targeted as a result of political motives and internal HMRC investigation targets.
Whatever the case, and whatever the possible rights and wrongs, it is essential that expats respond promptly to local tax authorities operating on behalf of HMRC – and the first component of this should be ensuring reliable expat financial advice together with jurisdictional legal advice.
Once this has been done there may, depending on the individual case, be plenty of scope for challenging the recovery of the claimed liability using MARD procedures.
Keith Littlewood is Blacktower Financial Management’s Regional Manager covering Murcia and 
British expats in the Netherlands are experiencing a difficult time at the moment. Not only do they have to deal with continued uncertainties over Brexit as well as government plans to overhaul the 30% expat tax break, they are also now having to digest news that the Dutch government is readying itself to publish new legislation regarding dual nationality.